The Dutch Ministry of Finance will not introduce new measures targeting the use of multiple BVs to optimise the earnings stripping threshold, at least for now. State Secretary Eerenberg confirmed this in a letter to the Dutch Parliament, concluding that none of the options examined are suitable for introduction at this stage.

The background: under the current earnings stripping rule (article 15b Dutch Corporate Income Tax Act, implementing the ATAD interest limitation), interest deductions are limited to 24.5% of EBITDA or €1 million per entity, whichever is higher. Real estate investors who hold properties across separate BVs can benefit from that €1 million threshold multiple times, i.e., once per entity. This practice has drawn scrutiny from the Dutch Tax Authority.

Eerenberg examined three policy options: (i) a group-wide threshold of €1 million, (ii) a reduced threshold of €200,000 for real estate entities financed largely through group loans or (iii) extending another rule (article 10a) to deny interest deductions on group loans used to finance third-party rental property. All the options have some disadvantages.

More importantly, the European Commission is expected to present a proposal on 24 June 2026, which will likely include a simplification of the earnings stripping rule. Leaked indications suggest the fixed threshold may increase, the deduction ratio may rise from 24.5% to 30% of EBITDA, and external financing may be excluded altogether. Eerenberg prefers to assess those changes before committing the Netherlands to its own course.

Good news for now and we are looking forward to the EU proposal and discussing the overall impact with you.

Svalner Atlas has advised Vendus on tax matters in connection with the acquisition of 51 retail properties at an underlying property value of approx. SEK 2.7 billion.

The transaction includes the acquisition of 35 retail properties from Trecore Fastigheter, owned by ICA Fastigheter and Bonnier Fastigheter, and in addition 16 retail properties are acquired directly from ICA Fastigheter. All properties are let to grocery retailer ICA under long-term lease agreements. As part of the transaction, ICA Fastigheter and Bonnier Fastigheter will become new shareholders in Vendus alongside existing principal shareholders Nordika and MEL & ME.

For further information in relation to the acquisition, see Vendus’ newsroom.

Svalner Atlas has provided financial and tax due diligence services for MVI in connection with the establishment of Kinra. Read more here or contact John Hovsenius or Karl Wichman for more information.

Svalner Atlas Advisors has entered into an agreement to join forces with Ryan, the world’s largest independent tax services and software provider. The transaction marks a significant milestone in Svalner Atlas’ growth journey and substantially strengthens Ryan’s presence and capabilities across the European market.

Founded through the combination of leading independent advisory firms across Northern Europe, Svalner Atlas has established itself as one of the region’s premier independent tax and transaction advisory groups, with over 450 professionals across multiple European markets.

“Over the past years, we have built a highly respected firm with an exceptional team, a strong entrepreneurial culture, and a client offering that combines local expertise with international reach. By joining Ryan, a firm that shares our entrepreneurial mindset, commitment to quality, and ambition to build a leading international advisory platform, we gain access to a stronger platform for continued growth, expanded capabilities, and broader international reach, while remaining true to our culture and client-centric approach.”

— Viktor Sandberg, Group CEO of Svalner Atlas

Headquartered in Plano, Texas, Ryan is widely recognised as a leading global tax services and software provider. With more than 7,100 professionals spanning multiple continents, Ryan combines deep tax expertise with innovative technology to help organisations manage complexity, reduce tax burden, and unlock capital for growth. The firm serves many of the world’s largest multinational companies through a comprehensive suite of tax advisory, compliance, recovery, advocacy, and technology solutions.

“This transaction is an important milestone in Ryan’s continued European growth strategy. Svalner Atlas Advisors has built an exceptional reputation for delivering cross-border tax and transaction advisory services across the region. Their strong local presence, international reach, and client-focused culture align closely with Ryan’s values and strategic vision.”

— G. Brint Ryan, Chairman and CEO of Ryan

The transaction represents a successful exit for Consolid, the Stockholm-based private equity firm that backed Svalner Atlas at its formation in 2023 and supported the group’s expansion across the Nordics and Benelux. The move creates a powerful platform for continued expansion across Europe, strengthening support for multinational clients, private equity firms, and large international businesses through highly specialised advisory services. Combining Svalner Atlas’ deep advisory expertise with Ryan’s global scale and technology-enabled capabilities creates new opportunities for long-term value creation for clients across the region.

Svalner Atlas will continue to operate under its existing brand, with its current leadership team and organisational structure ensuring continuity for clients. Viktor Sandberg will continue as President of Northern Europe and join the Ryan Tax Holdings board.

About Ryan

Ryan is an award-winning global tax services and software provider, and the largest firm in the world dedicated exclusively to business taxes. Its team of more than 7,100 professionals serves over 74,000 clients in more than 80 countries.

For more information, visit www.ryan.com.

Svalner Atlas Finland, part of Svalner Atlas Advisors, has provided financial and tax due diligence services for Lassila & Tikanoja plc in connection with the acquisition of Kempeleen Siirtokuljetus Oy and Kempeleen Jätekuljetus Oy. Lassila & Tikanoja is a leading Nordic circular economy company. Kempeleen Siirtokuljetus Oy and Kempeleen Jätekuljetus Oy form a group specializing in waste management and recycling services in Nort Ostrobothnia region. The transaction is subject to approval by the Finnish Competition and Consumer Authority.

For more information please contact Juha Lösönen or Antti Lehtimaja.

We offer our clients a wide range of expert services as tailored turnkey solutions, designed to meet their individual needs from planning through to implementation. We are a passionate and dedicated team of experienced professionals with a shared goal of serving our clients as comprehensively as possible.

How can we help you?

In addition to our close-knit working community, another key strength of our business is our committed partnership, which works purposefully alongside our people to support our long-term success.

Piia Ahonen has been invited to join Svalner Atlas Finland as a Partner as of 1 June 2026. At the same time, she will assume leadership of our Indirect Tax practice.

In her new role, Piia will be responsible for the strategic development, growth and leadership of the Indirect Tax practice. Her responsibilities will include strengthening our service offering, driving business growth, and leading the team’s operations.

Piia joins Svalner Atlas from Hannes Snellman, where she has served as a Specialist Partner since 2019. She has more than 25 years of experience in indirect taxation, and her career also includes previous roles at the Finnish Tax Administration and EY.

Piia is known for her deep expertise in indirect taxation, her solution-oriented approach, and her practical way of engaging with both clients and colleagues. She combines strong technical knowledge with commercial understanding, clear communication, and extensive experience in developing expertise within teams.

“Piia is a highly respected professional among both clients and colleagues. She has a strong perspective on how indirect tax advisory is evolving and how we can serve our clients even better,” says Petteri Rapo, Managing Partner of Svalner Atlas Finland.

“I am excited about this new phase in my career and the opportunity to become part of Svalner Atlas’s growth journey, which I have followed in the market for some time. I look forward to working with my new colleagues and to creating the greatest possible value for our clients both in Finland and internationally,” says Piia.

Svalner Atlas Finland is part of the Svalner Atlas Advisors group. We provide indirect tax advisory services in both domestic and cross-border matters as part of an integrated Northern European expert network, supported by our global partner coverage. Read more about us.

Svalner Atlas Finland, part of Svalner Atlas Advisors, has provided financial and tax due diligence services for Aspira Partners in connection with launching Census, a leading Finnish SME-focused audit and advisory services group. Census was formed by combining five regional audit firms (SYS Audit, Tiliextra, Auditus, HJL Audit and Tase-Koivu) with tax, legal, HR and corporate finance advisory firm Lecklé.

For more information please contact Juha Lösönen or Antti Lehtimaja.

We offer our clients a wide range of expert services as tailored turnkey solutions, designed to meet their individual needs from planning through to implementation. We are a passionate and dedicated team of experienced professionals with a shared goal of serving our clients as comprehensively as possible.

How can we help you?

The success of our organization is built on the ability of exceptional individuals to combine deep expertise, strong business understanding, and bold innovation to meet our clients’ evolving needs. The insight and networks brought by experienced professionals further strengthen our ability to grow and succeed in a changing business environment.

We are pleased to announce that Sakari Helminen (LL.D.) has joined to strengthen our Legal practice in a Senior Advisor role as of 18 May 2026.

Sakari is a widely recognized legal professional with more than 30 years of experience in complex corporate transactions and transactional advisory. He joins Svalner Atlas from EY, where he has worked since 2007, most recently as a Senior Advisor. Previously, he served as a Partner, Head of Transaction Law in Helsinki, and a member of the Nordic Life Sciences leadership team.

“Sakari is a highly regarded professional, appreciated by both clients and colleagues. He brings exceptional experience in demanding corporate transactions as well as strong networks across multiple industries. His expertise significantly strengthens our Legal practice and supports our ambition to build an even stronger and more comprehensive advisory organization,” says Petteri Rapo, Managing Partner of Svalner Atlas Finland.

Sakari’s arrival further enhances our capabilities particularly in M&A, financing, and due diligence engagements both in Finland and internationally, and supports the continued growth of our Legal practice. He also has extensive experience in IPOs and private equity transactions across various industries. In addition, Sakari is a respected expert and author in company law.

“Svalner Atlas is a fast-growing advisory firm where high-level expertise and a strong collaborative culture come together. I look forward to supporting the development of the Legal practice and working together with a highly skilled team for the benefit of our clients,” says Sakari Helminen.

We warmly welcome Sakari and wish him every success in his new role!

VAT risks in international supply chains often are a result of misalignment between logistics, contractual arrangements, and the chosen Incoterms. When legal responsibilities and physical movements do not support the intended VAT treatment, companies can face unexpected registration obligations, incorrect zero-rating, or problems with the deductibility of import VAT. This is why VAT planning should start long before the first invoice is issued.

International supply chains offer commercial advantages, but they also introduce complexity, especially in VAT, that is easily underestimated. In cross-border trade, VAT treatment is determined by facts: where goods are located, who controls them at each stage, and when responsibility and risk shift between parties.

Two factors are particularly decisive:

1. How goods physically move, and
2. How contractual responsibilities are defined, particularly through Incoterms.

Misalignment between these two areas is one of the most common sources of VAT risk in international supply chains.

Commercial and logistics teams focus on delivery efficiency, risk allocation, and cost. What is often overlooked is that these same decisions determine VAT obligations, registration requirements, and reporting positions, sometimes in several countries at once.

This misalignment can lead to misclassified supplies such as incorrect zero-rating for exports or intra-Community supplies or in using the wrong company as the importer of goods. Such mistakes in turn can lead to VAT registration obligations in unexpected jurisdictions or compliance penalties due to late filing or non-deductibility of the input or import VAT. These issues often go unnoticed until an audit or until several years of incorrectly filed returns need correction, thus often accompanied with hefty penalties when finally detected.

Incoterms define the responsibilities between seller and buyer, including delivery obligations, risk transfer, and transport arrangements. However, they are frequently misunderstood as merely “logistics terms”.

From a VAT perspective, Incoterms both help determine and affect which party is responsible for the transport, where the supply takes place, who acts as importer of record, whether certain simplifications (such as triangulation) can be applied to the transaction, whether zero-rating conditions are met and where VAT registration may be required.

For example:

• If a company uses DDP or DAP incorrectly, it may unintentionally become the importer in another country, triggering VAT registration and compliance obligations it never planned for.
• Using EXW or FCA in a cross-border context may in certain situations prevent the seller from being able to prove export, risking zero-rating.
• Similarly, using EXW or FCA in a chain supply would prevent the parties from using the triangulation simplification, thus triggering a VAT registration liability for the middle company in the chain.

And the opposite also holds true: when Incoterms are chosen strategically and aligned throughout the supply chain, especially in chain transactions, companies can often avoid unnecessary VAT registrations, simplify reporting, and manage cross-border movements far more efficiently.

The good news: most VAT risks in international supply chains are preventable when assessed early.

Key steps include:

• Reviewing supply chains end-to-end (physical and contractual flows)
• Aligning Incoterms with actual commercial intentions
• Identifying VAT registration triggers before they arise
• Ensuring contracts support VAT treatment
• Documenting evidence requirements
• Training operational and commercial teams

Early analysis ensures that the VAT treatment matches reality, not the other way around.

Incoterms determine responsibilities, but VAT rules determine obligations. Used together, they provide a clear structure for compliant and efficient trade. Used separately, they often create uncertainty and risk.

International supply chains are becoming more complex, not less. VAT should not be treated as an administrative afterthought, but rather as a structural part of how cross-border trade functions. Companies that invest in aligning Incoterms and actual supply flows typically experience fewer surprises, smoother logistics processes, and stronger long-term VAT compliance. More importantly, they reduce the risk of being forced into reactive corrections when it is already too late.

Managing VAT in international supply chains does not need to be burdensome, but it does require clarity and foresight.

Svalner Atlas Advisors supports companies by:

• Reviewing supply flows and contractual structures
• Analysing Incoterms and aligning them with the correct VAT treatment
• Identifying risks before they materialise
• Helping project, finance, and logistics teams understand how VAT interacts with commercial decisions
• Providing internal VAT trainings tailored for sales, procurement, project management, and finance teams
• Ensuring compliance obligations are met efficiently across jurisdictions through Svalner Atlas Advisors’ trusted cooperation network